Whistleblowing Policy

We are committed to conducting our business with honesty and integrity, and we expect all employees to maintain high standards in accordance with our Code of Conduct. However, all organisations face the risk of things going wrong from time to time, or of unknowingly harbouring illegal or unethical conduct. A culture of openness and accountability is essential in order to prevent such situations occurring or to address them when they do occur.

Employees may also, in properly carrying out their duties, have access to, or come into contact with, information of a confidential nature. Your terms and conditions of employment provide that, except in the proper performance of your duties, you are forbidden from disclosing, or making use of such confidential information in any form whatsoever. However, the law allows employees to make “protected disclosures” of certain information. In order to be protected a disclosure must relate to a specific subject matter and must also be made in an appropriate way. Whistleblowing protection is confined to a disclosure which, in the reasonable belief of the employee making the disclosure, is made in the public interest.

1. Purpose of Policy

The aims of this policy are:

1. To encourage employees to report suspected wrongdoing as soon as possible, in the knowledge that their concerns will be taken seriously and investigated as appropriate, and that their confidentiality will be respected.
2. To provide employees with guidance as to how to raise those concerns.
3. To reassure employees that they should be able to raise genuine concerns in good faith without fear of reprisals, even if they turn out to be mistaken.

2. What is Whistleblowing?

1. Whistleblowing is the disclosure of information which relates to suspected wrongdoing or dangers at work. This may include:
   1. criminal activity;
   2. miscarriages of justice;
   3. danger to health and safety;
   4. damage to the environment;
   5. failure to comply with any legal obligation or regulatory requirements;
   6. financial fraud or mismanagement;
   7. breach of our internal policies and procedures including our Code of Conduct;
   8. conduct likely to seriously damage our reputation;
   9. unauthorised disclosure of confidential information;
   10. the deliberate concealment of any of the above matters.
2. A whistleblower is a person who raises a genuine concern in good faith relating to any of the above. If you have any genuine concerns related to suspected wrongdoing or danger affecting any of our activities (a whistleblowing concern) you should report it under this policy.
3. This policy should not be used for complaints relating to your own personal circumstances, such as the way you have been treated at work. In those cases you should use the Grievance Procedure or Anti-harassment and Bullying Policy as appropriate.
4. If you are uncertain whether something is within the scope of this policy you should seek advice in confidence from the CFO.

3. Raising a Whistleblowing Concern

1. We hope that in many cases you will be able to raise any concerns with your line Manager. You may tell them in person or put the matter in writing if you prefer. They may be able to agree a way of resolving your concern quickly and effectively. However, where the matter is more serious, or you feel that your line Manager has not addressed your concern, or you prefer not to raise it with them for any reason, you should contact the CFO or CEO.
2. We will arrange a meeting with you as soon as possible to discuss your concern. You may bring a colleague to any meetings under this policy. Your companion must respect the confidentiality of your disclosure and any subsequent investigation.
3. We will take down a written summary of your concern and provide you with a copy after the meeting. We will also aim to give you an indication of how we propose to deal with the matter.

4. Confidentiality

1. We hope that employees will feel able to voice whistleblowing concerns openly under this policy. However, if you want to raise your concern confidentially, we will make every effort to keep your identity secret. If it is necessary for anyone investigating your concern to know your identity, we will discuss this with you.
2. We do not encourage employees to make disclosures anonymously. Proper investigation may be more difficult or impossible if we cannot obtain further information from you. It is also more difficult to establish whether any allegations are credible and have been made in good faith. Whistleblowers who are concerned about possible reprisals if their identity is revealed should discuss their concerns with the CFO and appropriate measures can then be taken to preserve confidentiality.

5. External Disclosures

1. The aim of this policy is to provide an internal mechanism for reporting, investigating and remedying any wrongdoing in the workplace. In most cases you should not find it necessary to alert anyone externally.
2. The law recognises that in some circumstances it may be appropriate for you to report your concerns to an external body such as a regulator. It will very rarely if ever be appropriate to alert the media. We strongly encourage you to seek advice before reporting a concern to anyone external.
3. Whistleblowing concerns usually relate to the conduct of our staff, but they may sometimes relate to the actions of a third party, such as a customer, supplier or service provider. The law allows you to raise a concern in good faith with a third party, where you reasonably believe it relates mainly to their actions or something that is legally their responsibility. However, we encourage you to report such concerns internally first. You should contact either your line Manager or the CFO for guidance.

6. Investigation and Outcome

1. Once you have raised a concern, we will carry out an initial assessment to determine the scope of any investigation. We will inform you of the outcome of our assessment. You may be required to attend additional meetings in order to provide further information.
2. In some cases we may appoint an investigator or team of investigators including employees with relevant experience of investigations or specialist knowledge of the subject matter. The investigator(s) may make recommendations for change to enable us to minimise the risk of future wrongdoing.
3. We will aim to keep you informed of the progress of the investigation and its likely timescale. However, sometimes the need for confidentiality may prevent us giving you specific details of the investigation or any disciplinary action taken as a result. You should treat any information about the investigation as confidential.
4. If we conclude that a whistleblower has made false allegations maliciously, in bad faith or with a view to personal gain, the whistleblower will be subject to disciplinary action.

7. If You are Not Satisfied

1. While we cannot always guarantee the outcome you are seeking, we will try to deal with your concern fairly and in an appropriate way. By using this policy you can help us to achieve this.
2. If you are not happy with the way in which your concern has been handled, you can raise it with the CFO. Alternatively you may contact the CEO.

8. Protection and Support for Whistleblowers

1. It is understandable that whistleblowers are sometimes worried about possible repercussions. We aim to encourage openness and will support employees who raise genuine concerns in good faith under this policy, even if they turn out to be mistaken.
2. Employees must not suffer any detrimental treatment as a result of raising a concern in good faith. Detrimental treatment includes dismissal, disciplinary action, threats or other unfavourable treatment connected with raising a concern. If you believe that you have suffered any such treatment, you should inform the CFO immediately. If the matter is not remedied you should raise it formally using our Grievance Procedure.
3. Employees must not threaten or retaliate against whistleblowers in any way. Anyone involved in such conduct will be subject to disciplinary action.

CSWBP 10/2025